Lex Propria in Foro Proprio: Parallelization of criteria for determining the applicable law and international jurisdiction for
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This book explores the intersection of international private law and the international civil process and ways to build parallel systems of applicable law and international jurisdiction on the example of the category of the place of fulfillment of a contractual obligation. The first part of the work shows historical development, content and distinctive approaches to determining the place of fulfillment of a contractual obligation in the substantive law of several law and order, including Germany and Russia. The second part of the work analyzes the historical development of the conflict binding to the place of fulfillment of the contractual obligation from Savigny to our time, and also shows a gradual refusal of European law and order to use this binding and the transition to the theory of characteristic execution. The third part of the work is devoted to the consideration of the scene of a contractual obligation as the basis of international jurisdiction in several national law and order, as well as the modern law of the European Union. The fourth and final part of the work offers ways to bring together international private law and the international civil process based on the theory of characteristic execution. The book is written on the basis of literature in English, German, French and Russian using the latest developments of foreign private doctrine. Designed for teachers, graduate students and students of law universities, as well as specialists in international private law and international civil process
Author:
Author:Levina Daria Aleksandrovna
Cover:
Cover:Hard
Category:
- Category:Law & Legal
- Category:Politics & Social Science
- Category:Reference books
Publication language:
Publication Language:Russian
Age restrictions:
Age restrictions:0+
ISBN:
ISBN:978-5-9998-0378-8
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